OFAC

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Glossary · Sanctions

OFAC

OFACAlso called office of Foreign Assets Control

Definition

OFAC, the Office of Foreign Assets Control, is the US Treasury office that administers and enforces US economic and trade sanctions. It publishes the Specially Designated Nationals (SDN) list, issues licences and guidance, and imposes civil penalties. US persons must block property of listed parties and generally cannot deal with them.

OFACSDN LISTLICENCESENFORCEMENT
Fig. 1 · OFAC
IEEPA · 21st Century Peace through Strength Act · OFAC recordkeeping rule
Key rulesIEEPA · 21st Century Peace through Strength Act · OFAC recordkeeping rule · OFAC compliance framework
Applies toUS persons and transactions within US jurisdiction
RegionsUS
01

How it works

OFAC acts under presidential executive orders and statutes such as the International Emergency Economic Powers Act. It designates people, companies, vessels and countries, adds them to its lists and publishes general and specific licences that permit some dealings. Banks screen customers and payments against OFAC lists, block matching property, reject prohibited transactions and report both to OFAC within 10 business days.

US sanctions apply strict civil liability, so a firm can be penalised without knowing it broke the rules. Dollar payments, US branches and US staff bring many non-US firms into scope. Since 2024 the statute of limitations for sanctions violations is 10 years, and OFAC record-keeping rules now match. OFAC's 2019 framework sets out the compliance programme it expects.

Step 1ScreenCheck customers and payments against OFAC lists.
Step 2BlockFreeze property of designated parties.
Step 3RejectRefuse prohibited transactions that need no blocking.
Step 4ReportFile blocking and reject reports within 10 business days.
Step 5Keep recordsRetain transaction records for 10 years.
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The rules

US · 28 December 1977IEEPAInternational Emergency Economic Powers Act, 50 U.S.C. 1701 to 1706

Lets the President block property and bar transactions in a declared national emergency, the basis for most OFAC programmes.

US persons and transactions within US jurisdiction
US · 24 April 202421st Century Peace through Strength Act21st Century Peace through Strength Act, section 3111

Extends the statute of limitations for civil and criminal sanctions violations from five to 10 years.

Violations of IEEPA and the Trading with the Enemy Act
US · 21 March 2025OFAC recordkeeping rule31 CFR 501.601, records and recordkeeping requirements, final rule

Requires transaction and blocked property records to be kept for at least 10 years.

Persons engaging in transactions subject to OFAC rules
US · 2 May 2019OFAC compliance frameworkA Framework for OFAC Compliance Commitments

Sets out five components OFAC expects in a sanctions compliance programme, starting with management commitment and risk assessment.

Organisations subject to US jurisdiction
03

Common questions

Does OFAC apply to non-US firms?

OFAC rules bind US persons, including US branches of foreign banks. Non-US firms are caught when they use US dollars cleared through US banks, US staff or US goods, and some programmes add secondary sanctions.

What is the SDN list?

The Specially Designated Nationals and Blocked Persons List is OFAC's main sanctions list. US persons must block property of listed parties. Entities 50% or more owned by listed persons are also blocked.

Can OFAC fine a firm that did not know it breached sanctions?

Yes. Civil liability for US sanctions breaches is strict. OFAC weighs knowledge, the compliance programme, cooperation and voluntary self-disclosure when setting the penalty amount under its enforcement guidelines.